Legal
Privacy Policy
Last Updated: 15 April 2025 · Effective Date: 15 April 2025
1. Introduction
Sinar Capital ("we", "us", "our") is committed to protecting the personal data of everyone who visits our website or enrolls in our courses. This Privacy Policy describes the categories of personal data we collect, the purposes for which we use that data, how long we retain it, and the rights you have as a data subject under Malaysian law.
This policy applies to information collected through our website at sinarcap.info, our course enrolment process, and our adviser consultation sessions. If you have any questions about this policy, contact us at [email protected].
2. Data We Collect
We collect only the personal data needed to operate our courses and respond to enquiries. This includes:
- Contact information: Name, email address, and telephone number provided through our enquiry form or during enrolment.
- Course-related information: The programme you enrolled in, session attendance records, and materials dispatched to you.
- Consultation notes: Information shared during adviser consultations, to the extent it relates to your household coverage situation. These notes are used solely to support your ongoing sessions.
- Website usage data: Standard server logs including IP address, browser type, and pages visited, collected automatically when you use our site.
- Cookie data: See our Cookie Policy for details of what cookies we use and why.
Legal basis for processing: Where you provide data through our enquiry form, we process it on the basis of your consent. Course enrolment data is processed as necessary to fulfil the contract between you and Sinar Capital. Analytics data is processed on the basis of our legitimate interest in understanding how our site is used.
3. How We Use Your Data
We use the personal data we collect for the following purposes:
- To respond to your enquiries and process course enrolments
- To send you course materials, session reminders, and administrative communications related to your enrolment
- To support your adviser consultations and maintain continuity across sessions
- To improve our website and course content based on usage patterns
- To comply with any legal or regulatory obligations that apply to us
We do not use your personal data for unsolicited marketing purposes. If we wish to send you information about future courses after your enrolment ends, we will ask for your separate consent.
4. Data Sharing
We do not sell, rent, or share your personal data with insurers, takaful operators, financial product distributors, or third-party marketing companies. We have no commission arrangements that would create an incentive to share your information with product providers.
We may share your data with the following categories of service providers, but only to the extent necessary for them to deliver services on our behalf:
- Webinar platform providers (for session delivery)
- Email service providers (for administrative communications)
- Postal and printing services (for materials dispatch)
- Analytics providers (for website usage data only, on an anonymised basis)
All service providers are contractually required to handle your data in accordance with applicable Malaysian data protection law.
5. Data Protection Measures
We take reasonable steps to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These steps include:
- HTTPS encryption for all data transmitted via our website
- Access controls limiting which staff members can view participant data
- Secure file storage for consultation notes and enrolment records
- Regular review of access logs for our administrative systems
In the event of a data breach affecting your personal data, we will notify you and the relevant regulatory authority in accordance with our obligations under Malaysian law.
6. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy, or as required by law. Our standard retention periods are:
- Enquiry data: 12 months from the date of enquiry, if no enrolment follows
- Enrolment and course records: 7 years from course completion (to satisfy tax and accounting requirements)
- Consultation notes: Retained for the duration of the programme, then archived for 2 years before deletion
- Website usage logs: 6 months on a rolling basis
7. Cookies
Our website uses cookies to support basic functionality and to understand how visitors use the site. You can manage your cookie preferences at any time on our Cookie Policy page. Essential cookies cannot be disabled as they are required for the site to function.
8. Your Rights
Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights in relation to your personal data:
- Right to access: Request a copy of the personal data we hold about you
- Right to correction: Request that inaccurate or incomplete data be corrected
- Right to withdraw consent: Withdraw consent for processing where consent was the legal basis
- Right to limit processing: Request that we limit how we use your data in certain circumstances
- Right to complain: Lodge a complaint with Malaysia's Department of Personal Data Protection (JPDP) if you believe your rights have not been respected
To exercise any of these rights, email us at [email protected]. We will respond within 21 days. We may need to verify your identity before processing your request.
9. Third-Party Links
Our website may contain links to external sites, including regulatory bodies and webinar platforms. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policy of any external site before sharing personal data with it.
10. Children's Privacy
Our courses are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted personal data to us, please contact us so that we can delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of the page. If the changes are material, we will notify enrolled participants by email. Continued use of our website after any changes constitutes acceptance of the updated policy.
12. Contact Us
For any privacy-related question, data access request, or complaint, please reach us by email or post:
Sinar Capital — Data Privacy
Persiaran Lagoon 9, 47500 Subang Jaya, Selangor, Malaysia
Email: [email protected]
Phone: +60 3-7918 4520